ESRS Standard
ESRS Standard
The term"Policy" is synonymous with the term"Policy", which is used within the German version of the ESRS Standard.
7 The company shall disclose its policies relating to aspects of corporate governance and explain how it promotes its corporate culture.
8. the objective of this disclosure requirement is to provide an understanding of the extent to which the company has policies in place to identify, assess, manage and/or improve its material impacts, risks and opportunities relating to aspects of corporate governance. It also aims to provide an understanding of the company's approach to Corporate culture.
9. the disclosures required by paragraph 7 shall include how the company establishes, develops, promotes and evaluates its corporate culture.
10. the disclosures required by paragraph 7 shall cover the following items related to the company's policies on aspects of corporate governance:
(a) A description of its mechanisms for identifying, reporting and investigating concerns about unlawful conduct or conduct inconsistent with its code of conduct or similar internal rules, and whether it considers reporting from internal and/or external stakeholders.
b) If the company does not have policies in place to combat Corruption or Bribery in line with the United Nations Convention against Corruption (127), it shall state this and explain whether it plans to introduce such policies and, if so, the timetable for doing so.
c) How the company protects whistleblowers, including:
i. Details of the establishment of internal reporting channels for whistleblowers, including whether the company provides information and training to its own workforce/own workers, and information on the designation and training of employees who receive such reports.
ii. Actions taken to protect own employees who are whistleblowers from retaliation in accordance with the applicable legislation implementing Directive (EU) 2019/1937 of the European Parliament and of the Council (128).
d) If the company does not have a whistleblower protection policy (129), it shall state this and indicate whether it plans to introduce such a policy and, if so, the timetable for doing so.
e) In addition to the procedures for following up on whistleblower reports in accordance with the applicable legislation implementing Directive (EU) 2019/1937, whether the company has procedures in place to promptly, independently and objectively investigate Incidents related to corporate governance, including cases of Corruption and Bribery.
f) Where applicable, whether the company has policies relating to animal welfare.
g) The company's policy on internal governance training, including target audience, frequency and scope.
h) The functions within the company that are most vulnerable to Corruption and Bribery.
11. companies that are subject to legal requirements under national law implementing Directive (EU) 2019/1937 or equivalent legal requirements in relation to whistleblower protection may comply with the disclosure obligation under paragraph 10(d) by declaring that they are subject to such legal requirements.
Application Requirements (AR)
Application Requirements (AR)
AR 1. the company may take into account the following aspects when determining its disclosures under paragraph 7:
(a) the aspects of Corporate culture that are considered and discussed by the Administrative, management and supervisory bodies and the frequency with which this is done,
(b) the key issues that are promoted and communicated as part of the Corporate culture,
(c) the manner in which members of the company's Administrative, management and supervisory bodies provide guidance to promote a corporate culture; and
d) specific incentives or tools for the company's own workforce to promote and support the Corporate culture.
Examples from past practice
Examples from past practice
Examples serve only as an indication of how a disclosure requirement has been reported by other companies to date. Audited ESRS reports are not yet available. There is no guarantee of accuracy and completeness.
G1-1 - Policies for Corporate Governance and Corporate culture
Code of conduct and ethical guidelines
Our Code of Conduct and internal guidelines form the foundation of our Corporate culture. They provide orientation and promote a way of working that is based on integrity, responsibility and the common goal of ensuring ethical business practices. As a globally active company, we are aware of the far-reaching impacts of our actions. We are therefore committed to integrating the principles of the International Labor Organization (ILO) on fundamental rights and the Organization for Economic Cooperation and Development (OECD) Guidelines for Multinational Enterprises into our processes. We ensure that our activities and practices respect and promote the dignity, rights and well-being of all people in our Value chain.
Anti-Corruption and Anti-Bribery Policy
Our Anti-Corruption and Anti-Bribery Policy complements our Global Code of Conduct and defines minimum standards to ensure that all company activities are conducted ethically and with integrity. This policy is designed to ensure compliance with applicable anti-bribery laws, both nationally and internationally. It clearly defines what is meant by Bribery, Corruption and improper payments and sets out what behavior is considered acceptable.
In addition, the giving and receiving of gifts and the acceptance or granting of invitations or hospitality are subject to special approval requirements. Depending on the value of these benefits, approval is required, which is granted via a special registration tool. We have set country-specific limits for each national company to ensure transparency and compliance.
Whistleblowing policy
To reinforce our ethical principles, we have introduced a transparent and open reporting system. This system enables us to identify breaches of the law at an early stage, act quickly and continuously improve operational processes and our internal control system. The whistleblowing system is a central component of our compliance culture and serves exclusively to promote compliant behavior - it is not a system for punishment or sanctioning.
Whistleblowers enjoy comprehensive protection through strict confidentiality and a ban on pressure or reprisals. This is additionally safeguarded by a voluntary company agreement. We provide a secure and anonymous channel via a digital platform that meets the highest standards of confidentiality and identity protection. This ensures that both the integrity of our company and the rights of whistleblowers are protected at all times.
Our compliance organization and control mechanisms
We have established an independent compliance department that reports directly to the company management and operates throughout the Group. This department is divided into various specialized teams, each of which is responsible for specific compliance areas. Through clear responsibilities and representation rules, we ensure that all regulatory requirements are met at all times.
Our compliance organization comprises teams that deal with general compliance, the prevention of financial and legal violations and compliance with sanctions and embargoes. Each team is led by qualified experts who ensure that the respective requirements are monitored and implemented.
Mechanisms for risk monitoring and prevention of misconduct
The Compliance department plays a central role in identifying, reporting and investigating potential violations of applicable laws and internal guidelines. We have implemented a comprehensive system of guidelines, processes and control mechanisms that detect misconduct at an early stage, initiate the necessary consequences and, if necessary, inform the relevant authorities. We pay particular attention to the prevention of Corruption and Bribery. To this end, we have introduced clear actions and procedures based on transparency and responsibility to prevent unethical behavior and promote a culture of integrity.
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